CCPA NOTICE FOR JOB APPLICANTS

CCPA NOTICE FOR JOB APPLICANTS

Effective July 1, 2020

INTRODUCTION

We are excited that you are considering a career with ASR Group International, Inc., American Sugar Refining, Inc. and their affiliated companies (collectively, “ASR Group”). ASR Group provides this CCPA Notice for Job Applicants (the “Notice”) pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), to job applicants (“Applicants”) who are residents of the State of California. Any terms defined in the CCPA have the same meaning when used in this Notice. All references to we, us, and our in this Notice refer to ASR Group. If an Applicant is hired by ASR Group, then ASR Group’s Employee Privacy Notice will apply.

USE OF PERSONAL INFORMATION

ASR Group may use or disclose the Personal Information we collect regarding Applicants for one or more of the following business purposes: 1) To comply with state and federal law(s) requiring businesses to collect, monitor, maintain or transfer certain records regarding applicants or applications for employment or contract work, including demographic characteristics; 2) To assess ability, fitness or eligibility of applicants to fulfill or perform prospective job duties and work in relevant corporate locations and environments; 3) To schedule travel, and pay for or reimburse job applicants for covered business expenses related to the job application, interview or similar expenses; 4) To comply with the provisions of collective bargaining agreements as to prospective employees; 5) To maintain and protect the rights, security and safety of job applicants, our personnel, clients and others, as well as our facilities, premises and other property; 6) To respond to law enforcement requests and, as required by applicable law, court order, or governmental regulations; 7) To provide job applicants with information, products or services related to the job opportunity or that they request from us; 8) To provide job applicants with notices or announcements concerning our business operations, opportunities or policies that may be relevant and/or of interest to them; 9) To fulfill or meet the reason for which the information was provided to us by the applicant;  and/or 10) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred.

ASR Group will not collect additional categories of Personal Information or use the Personal Information collected for materially different, unrelated or incompatible purposes without providing prior notice.

COLLECTION OF PERSONAL INFORMATION

ASR Group may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (“Personal Information”).  The CCPA excludes the following from Personal Information: 1) Publicly available information that is lawfully made available from government records, 2) De-identified or aggregated information, 3) Information excluded from the CCPA’s scope, such as information covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information collected/maintained pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

In particular, ASR Group may collect the some of the following categories of Personal Information from or about Applicants:

 

Categories

Example

Collected

Identifiers

Name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Yes

Personal information categories listed in the CA Customer Records statute Cal. Civ. Code § 1798.80(e)

A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, etc. Some Personal Information included in this category may overlap with other categories.

Yes

Protected classification characteristics under CA or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), etc.

Yes

Commercial information

Records of personal property, products or services purchased, obtained, or considered or other purchasing or consuming histories or tendencies.

No

Biometric information

Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, face prints and voiceprints, iris or retina scans, keystroke, gait or other physical patterns, video security surveillance and sleep, health, or exercise data.

Yes

 

 

Internet or other similar network activity

Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.

No

Geolocation data

Physical location or movements.

No

Sensory data.

Audio, electronic, visual, thermal, olfactory or similar information.

No

Professional or employment-related information

Current or past job history or performance evaluations.

Yes

Non-public education information (per the Family Educational Rights and Privacy Act 20 U.S.C. Section 1232g, 34 C.F.R. Part 99)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.

Yes

 

 

Inferences drawn from other Personal Information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.

Yes

CONTACT US

If you have any questions or concerns about this Notice, please contact us at: 

ASR Group International, Inc.

Attention: Legal Department

One North Clematis Street, Suite 200

West Palm Beach, FL 33401

Phone: 561-366-5100

Fax: 561-366-5180

© Copyright 2020 ASR Group International, Inc. All rights reserved.